Title
Baby Bus Inc. vs. Minister of Labor
Case
G.R. No. 54223
Decision Date
Feb 26, 1988
Employee rendered unfit due to recurring strokes; awarded separation pay, emergency allowances, and overtime pay, affirmed by Supreme Court despite employer's challenge.
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Case Digest (G.R. No. 54223)

Facts:

  1. Employment Details:

    • Respondent Jacinto Mangalino worked with petitioner Baby Bus Inc. since June 1972 as an over-all inspector, earning P8.00 a day.
  2. Health Issues:

    • In April 1975, Mangalino suffered a stroke due to high blood pressure and was hospitalized.
    • He suffered subsequent strokes, rendering him unfit to report for work in May 1975.
  3. Claims Filed:

    • On September 13, 1976, Mangalino filed a complaint with Regional Office No. IV, Department of Labor, for illegal dismissal, non-payment of overtime pay, unpaid wages, and violation of P.D. 525 (emergency living allowance).
  4. Proceedings:

    • The case was set for compulsory arbitration. Mangalino submitted affidavits and documentary evidence, while Baby Bus Inc. failed to present evidence despite multiple hearings.
    • The Labor Arbiter ruled in favor of Mangalino, awarding separation pay and emergency allowances.
    • The National Labor Relations Commission (NLRC) modified the decision, and the Minister of Labor affirmed the NLRC's ruling.
  5. Petition to the Supreme Court:

    • Baby Bus Inc. filed a petition for certiorari, challenging the award of separation pay, emergency allowances, and overtime pay.

Issue:

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Ruling:

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Ratio:

  1. Separation Pay:

    • Article 285 of the Labor Code allows termination due to illness if continued employment is prejudicial to the employee's health. Separation pay is mandatory in such cases, even without illegal dismissal.
  2. Emergency Allowances:

    • Under P.D. 525, employees earning less than P600.00 a month are entitled to emergency allowances. Baby Bus Inc. failed to rebut Mangalino's entitlement to these allowances.
  3. Overtime Pay:

    • The NLRC's award of overtime pay was based on the days Mangalino actually worked, as evidenced by his submissions. The petitioner's failure to present counter-evidence weakened its case.
  4. Finality of Quasi-Judicial Findings:

    • Factual findings of quasi-judicial agencies like the NLRC, supported by substantial evidence, are accorded respect and finality by the courts.


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